Turkey sector Operational Programme Environment and Climate Change



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Annexes


ANNEX I: SWOT Analysis - Turkish Environmental Sector

Key Area

Sub-areas

Strengths

Weaknesses

Legal

EU

  • On-going transposition and compliance with EU Acquis.

  • EU Integrated Environmental Approximation Strategy21 (2007-2023) (Turkish UÇES) has been approved by the High Planning Council.

  • Working documents, such as several environmental DSIPs have been prepared. These are Directive-Specific documents detailing the investment planning for environmental heavy-cost investment projects for, amongst others, the water, wastewater and waste sectors in compliance with relevant EC Directives.

  • RIA (Regulatory Impact Assessment) Documents were prepared

  • Turkey's participation in the relevant activities and training of Civil Protection Mechanism was initiated in 2011 and has continued so far.

  • Many laws still to be approximated, however the ‘gap’ is closing.

  • High cost for approximating EU environmental legislation

  • EU Integrated Environmental Approximation Strategy (2007-2023) (Turkish UÇES) has not been updated

National

  • The Environmental Law (No: 5491) lays down the legal basis for:

    • the responsibility of the municipalities, settlements and industrial zones for the delivery of environmental services;

    • the principles of ‘producer liability’ and ‘the polluter pays’;

    • use of environmental revenues (fees, fines) for environmental protection, prevention of pollution and rehabilitation and closure of old dumpsites;

    • Incentive for creation of representative local authority union bodies.

  • 10th NDP for 2014-2018 has been approved.

  • An UÇES document was prepared in 2006 and it will be updated.

  • Legislations/By-Laws adopted for harmonisation with the Water Framework Directive (WFD).

  • Water Management Coordination Board is established and Communique on Establishment, Duties and Working Procedures and Principles of Basin Management Committees is adopted in order to implement WFD and RBMPs.

  • Prepared/published national legislation within the context of EU Acquis harmonisation.

  • Sectoral Strategy Action Plans were prepared.

  • Turkish Law on the Right to Information, Law No:4982

  • Technological Disasters Action Plan is under preparation.

  • National Disaster Management Strategy Document and National Disaster Response Plan are being used by relevant authorities.

  • Draft legislations are ready (CAFE, NEC, IPPC, VOC, SEA, INSPIRE, mining wastes).

  • Climate Change and Air Management Coordination Board was established.

WATER

  • Water Law is being prepared and is almost complete.

  • The legislations related with drinking water and bathing water are ready and in force (in Ministry of Health).

  • Regulation on Water Pollution Control is in force.

  • Specific pollutants and related EQSs have been determined and they will be integrated into the By-law on Surface Water Quality Management.

  • Some duty and responsibility conflicts remain to be settled between the institutions,

  • Insufficient monitoring, inspection and enforcement and lack of reliable data (e.g. for monitoring performance of service providers).

  • Re-Organisation as a result of Municipality Law

  • There are problems in implementation of the legislation.

  • There is no regulatory impact assessment for some of the legislations.

  • The regulations being put in force without evaluating the readiness of the sector or without making any infrastructure investments. The applicability in rural areas.is a problem.

  • Stakeholder analysis in legislation preparation is insufficient.

  • Lack of CBRN (Chemical, Biological, Radiological and Nuclear) Action Plan (in accordance with the EU).

  • The problem of stakeholders not being able to get involved in the processes.

  • A complete declaration system for environmental domains including water abstraction, wastewater discharge and non-hazardous waste is still not available.

WATER

  • Fragmented responsibilities and competencies of different institutions regarding water monitoring.



Key Area

Sub-areas

Strengths

Weaknesses

Legal

National

WASTE

  • EU Acquis is 99% adopted (as it is indicated ToC and IQ tables).

  • By-law on Waste Management which will involve key principles of waste management policy in accordance with EU’s new Waste Framework Directive, is in preparation.

  • Hazardous Waste Declaration System is in use.

ENVIRONMENTAL MANAGEMENT FOR SUSTAINABLE DEVELOPMENT

CLIMATE CHANGE



  • Legally, there is relation between disaster management and climate change (by legal and activity means).

  • Climate change action plan is ready and is being monitored.

DISASTER MANAGEMENT

  • New institutional legal framework on the disaster and emergency management has been established.

  • AFAD operating under the Prime Ministry, is an institution having an extended regulatory and coordination roles and responsibilities in the area of disaster and emergency management.

  • Shift from crisis management to risk management approach has been issued.

HORIZONTAL

  • By-law on EIA which is fully harmonised with EIA Directive except transboundary issues is in force for a long time.

WASTE

  • There is not enough recycling.

ENVIRONMENTAL MANAGEMENT FOR SUSTAINABLE DEVELOPMENT

CLIMATE CHANGE



  • Need of increase public awareness to promotion of climate-friendly consumption patterns to combat with climate change.

NATURE PROTECTION

  • Insufficient capacity on the implementation of management plans.

  • The regulation for protected areas is not under a single authority’s responsibility, thus it causes lack of coordination.



Key Area

Sub-areas

Strengths

Weaknesses

Institutional

Human Resources

  • Awareness and sensitivity is increasing regarding the environment in all segments of society, especially among the youth.

  • Open policy of MoEU to employ highly-qualified and dynamic personnel. Additional TA already in place for preparation of projects/supervision and conducting capacity building activities.

  • Increased capacity of beneficiaries by using IPA funds.

  • Increasing number of qualified and experienced staff of institutions in the sector

  • Sufficient number of qualified scientists and technical personnel working on nature protection

  • By means of Law on metropolitan municipality; technical capacity of the municipality increased.

  • General Directorate of GIS was established.

  • General Directorate of Water Management was established.

  • Internal trainings of the institutions.

  • Trainings can be obtained from financing sources other than IPA.

  • Increasing awareness and sensitivity regarding the importance of disaster and emergency management.

  • Certain divisions of the central and local (municipal and regional) administration involved in the process of implementing environmental polices need strengthening in administrative, financial and technical capabilities required for the measurement, monitoring, planning, supervision, inspection, reporting as well as project development and implementation.

  • Apart from metropolitan municipalities, a limited number of municipalities have established (semi) independent bodies for the management of environmental services, staffed with suitably qualified personnel.

  • Administrative capacity needs strengthening.

  • Insufficient number of qualified scientists and technical personnel working on chemicals management

  • Lack of knowledge in terms of IT systems and GIS in local personnel (GIS and information technologies)

  • Not enough contribution from NGOs and the universities.

  • The capacity building activities are not institutionalized.

  • Lack of experts in the rural areas.

  • Lack of personnel job descriptions

  • Staff turnover and loss of accumulated know-how

Infrastructure

Capital Investment

  • National funds for co-financing of SOP activities is ensured.

  • Legal requirements are already set.

  • Financial resources dedicated to infrastructure investments and operations aimed at environmental protections which are heavy-cost investments do not meet the demand.

  • Municipalities with a GDP below the national average, face difficulties in the sustainability of their investment in infrastructure projects.

  • Relatively weak infrastructure for waste management, waste water management and air quality monitoring,

  • Lack of procedures and guidelines for the donors’ contributions in order to maximize the impact and effectiveness of the EU funds (leverage affect).



Key Area

Sub-areas

Strengths

Weaknesses

Institutional

Infrastructure

Operations

  • Water Management Coordination Committee has been established and made functional.

  • Water Management is based on the river basin approach.

  • There is an existing well-developed construction industry capable of undertaking the required capital works.

  • Modern technology and international standards have already been applied in several existing potable water, wastewater treatment and waste disposal facilities.

  • Facilities used for the management of water, wastewater and waste disposal have been substantially completed in the metropolitan municipalities so”lessons learnt” can be applied.

  • Substantial experience from IPA I period implementation.

  • Existence of central and local institutions dealing with nature protection issues.

  • Environmental Law sets basis for construction of WWTPs according to population of municipalities and capacities of the facilities.



  • Establishment of GD of WM to coordinate water management in Turkey based on the river basin approach in an integrated manner.

  • Local Basin Management Committees were established in every river basin.

  • There are many projects to combat with climate change which are conducted by public institutions and private sector.

  • Need for improvement of tools (inventories& databases) for the ease of accession, transparency and monitoring environmental quality.

  • Need for improvement of systems for special type of wastes (eg, WEEE&ELV collection)

  • Long tendering processes.

Water

  • Water management is not fully integrated in terms of assessment of impacts of investments on water status, and sequencing and coordination of them at basin level.

  • Insufficient and outdated infrastructure for water cycle management, resulting in ineffective potable water supply and ineffective collection and treatment of wastewater.

  • Losses and leakages in existing water supply need urgent remedy allied to good Operations & Maintenance (O&M) procedures.

  • Problems in operation of WWTPs due to lack of institutional and technical capacity in some municipalities

Waste

  • Systems for waste collection including separate waste collection, waste transportation and environmental-friendly waste treatment facilities are still incomplete and need further improvement.

  • Measures for waste minimization, re-use, recycling and recovery are still incomplete and need further improvement.

  • Secondary markets for re-cycled products, especially from composting, are still incomplete and need further improvement.

  • Studies on waste collection at source are still incomplete and need further improvement.

  • Rehabilitation of dumpsites is still incomplete and need further improvement.



Key Area

Sub-areas

Strengths

Weaknesses

Institutional

Infrastructure

Operations




Climate Change

  • Absence of research, technology and education center.

  • The possibility of duplication of projects since there are many projects related to climate change that are conducted by public institutions, private sector and NGOs and there isn’t any coordinator institution or center in Turkey that works to register and make an inventory of projects.

  • Insufficient infrastructure for research and education.

  • Insufficient financial resources to combat climate change

  • Lack of sufficient financial, technical and personnel capacity in local level to implementing the NCCAP and to combat with climate change.

Disaster Management

  • Not well coordinated and integrated knowledge and experience on the management process of the disaster types (natural and man-made/technological)

  • Variety of roles and responsibilities of the public institutions working on the disaster and emergency management

  • Lack of systematic approaches and integrated management process

  • Insufficient capacity in CBRN response expertise

Nature Protection

  • Insufficient monitoring and evaluation mechanism for protected areas.


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